1. The plaintiff's appeal is dismissed.

2. The costs of appeal shall be borne by the Plaintiff.

Purport of claim and appeal

The first instance court.

1. Details of the disposition;

A. On January 8, 198, the Plaintiff was established mainly for the wholesale and retail business of drugs and added the creative art sales business to the purpose of business on December 26, 2008.

As of December 31, 2009, B, the representative director of the plaintiff, holds 91.63% of the shares issued by the plaintiff and actually controls the plaintiff.

In addition, B is also owned and operated by Company C (B and its specially related persons holding 100% shares, hereinafter referred to as “C”), Company D (B holding 100% shares, hereinafter referred to as “D”); and hereinafter referred to as “B, etc.”), etc.

B. B, on September 15, 2010, sold I’s work J (hereinafter “instant art”) for KRW 1.85 billion among the art works owned by the Plaintiff through Ghanagalian Co., Ltd., a company engaged in the sale and brokerage (mediation) of art works, and received the total amount of the price (hereinafter “the instant money”) from the bank account in his/her personal name on the day.

C. B, as of September 16, 2010, was liable to the Plaintiff for a loan of KRW 3,681,487,283 (short-term loan) with respect to the Plaintiff. On September 17, 2010, B remitted the amount equivalent to the instant money to the Plaintiff as the repayment of the loan of KRW 1.85 billion with respect to B on the same day. Accordingly, the Plaintiff completed accounting as the repayment of the loan of KRW 1.85 million with respect to B on the same day.

From August 9, 2012 to November 6, 2012, the director of the Seoul Regional Tax Office conducted a corporate tax integration investigation with respect to the Plaintiff (hereinafter “instant tax investigation”). In the course of the investigation, it was revealed that the instant art works owned by the Plaintiff were deemed as art works owned by the Plaintiff as the representative director B private-owned art works, and that the said accounting accounting was made with the proceeds from sale.

E. Upon the confirmation of the foregoing facts, the Plaintiff cancelled all accounting accounts on the recovery of short-term loans as seen earlier as of October 1, 2012 and sold its assets to its holding company.